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Does flight time in a FFS (Level D) count towards the maximum flying hours permitted under flight time limitations?

e.g. you spend 4 hours in a simulator. Do those 4 hours come off your maximum flying hours for the 3 day period, 7 day period, 28 day period, 84 day period and the year?

A reference under EASA would be great if anyone has it, please!

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  • $\begingroup$ In the US, no. The definition in Part 117 of Flight Duty Period (FDP) and Block Hours are specific to aircraft and "for the purpose of flight" and similar language. While there can be contractual limitations on crew rest before a simulator training period, the FAA doesn't care. (Of course, time on duty, in the sim or classroom or otherwise all counts as time on duty that day if you then get into an aircraft to go fly.) We don't accrue FDP nor Block hour liability for time in the sim in FAA-land; dunno about EASA. (Probably depends on the exact language in those regs defining Block time.) $\endgroup$
    – Ralph J
    Aug 31, 2021 at 21:57
  • $\begingroup$ Related for FAA: How are the hours that count toward fatigue limits calculated by the FAA? $\endgroup$
    – user14897
    Aug 31, 2021 at 22:22

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I think they only count for the duty portion of ORO.FTL.210 Flight times and duty periods.

From EASA ORO.FTL.105, on definitions, sim time is duty but not flight as flight duty period includes one or more sectors, and the definition of sector specifically mentions an aircraft.

Quoting EASA ORO.FTL.105,

‘duty’ means any task that a crew member performs for the operator, including flight duty, administrative work, giving or receiving training and checking, positioning, and some elements of standby;

‘flight duty period ('FDP')’ means a period that commences when a crew member is required to report for duty, which includes a sector or a series of sectors, and finishes when the aircraft finally comes to rest and the engines are shut down, at the end of the last sector on which the crew member acts as an operating crew member;

‘sector’ means the segment of an FDP between an aircraft first moving for the purpose of taking off until it comes to rest after landing on the designated parking position.

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